Center for American Progress

CAP’s Comment on the Income-Driven Repayment Regulation

CAP’s Comment on the Income-Driven Repayment Regulation

In a comment letter submitted to the U.S. Department of Education, Bradley D. Custer discusses income-driven repayment regulation and the need for a student loan repayment system with a functional safety net.

The Center for American Progress is an independent, nonpartisan policy institute that is dedicated to improving the lives of all Americans through bold, progressive ideas, as well as strong leadership and concerted action. We envision and strive for a higher education system that provides a high-quality, affordable college education that prepares all students for participation in an inclusive economy and American public life. A student loan repayment system with a functional safety net is critical for achieving that goal.

The country’s debt-financed higher education system requires a complex array of programs to help students access and pay for college. Increased scrutiny of these programs, improvements in data, and the turmoil caused by a global pandemic have made it clear that the student loan repayment system is broken. We thank the department for recognizing the need to create an improved income-driven repayment (IDR) plan and for taking action through this regulation.

The hard work of the negotiated rule-making committee, as well as that of the experts in the department, is clearly represented in the department’s proposal. This plan is a monumental revision of the student loan system’s safety net, and opportunities to make such reforms do not come along often.

In this letter, we highlight the proposed changes that we believe are significant improvements to IDR and that should be carried forward. We also offer recommendations on how to improve the proposed rule to help more borrowers access student debt relief.

Click here to read CAP’s comment letter.

The positions of American Progress, and our policy experts, are independent, and the findings and conclusions presented are those of American Progress alone. A full list of supporters is available here. American Progress would like to acknowledge the many generous supporters who make our work possible.


Bradley D. Custer

Former Senior Policy Analyst


Higher Education Policy

The Higher Education team works toward building an affordable and high-quality higher education system that supports economic mobility and racial equity.

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